BEFORE THE DISTRICT AND SESSIONS JUDGE COURT AT 

IN THE MATTER OF

STATE
VS
(Mention the name of the accused)

FIR Number: (Mention the FIR number)

Under Section: (Mention the sections under which the FIR has been
filed)

Police Station: (Mention the name of the Police Station)

Accused under custody since (Give the date from when the accused
is in custody)

APPLICATION U/S 439 CRPC FOR GRANT OF BAIL ON BEHALF

OF THE ACCUSED (name of the applicant of the bail)

MOST RESPECTFULLY SUBMITTED AS UNDER:

1. That the present FIR has been registered on false and bogus
facts. The facts stated in the FIR are fabricated, concocted and
without any basis.

2. That the police has falsely implicated the applicant in the present
case, and arrested him although the applicant is a respectable
citizen of the society and is not involved any criminal case.

3. That the facts stated in the complainant against the applicant are
civil disputes and does not constitute any criminal offence at all.

4. That the applicant is not required in any kind of investigation nor

any kind of custodial interrogation is required.

5. That the applicant is having very good antecedents, he belongs to

good family and there is no criminal case pending against them.

6. That the applicant is a permanent resident and there are no

chances of his absconding from the course of justice.
7. That the applicant undertakes to present himself before the
police/court as and when directed.

8. That the applicant undertakes that he will not, directly or

indirectly make any inducement, threat or promise to any person
acquainted with the facts of the case so as to dissuade him from
disclosing such facts to the Court or to any police officer.

9. That the applicant further undertakes not to tamper with the

evidence or the witnesses in any manner.

10. That the applicant shall not leave India without the previous
permission of the Court.

11. That the applicant is ready and willing to accept any other
conditions as may be imposed by the Court or the police in
connection with the case.

12. That the Court below has failed to consider all the facts and
circumstances of the case and has wrongly dismissed the bail
application.
It is therefore prayed that the court may direct the release the
applicant on bail in the interest of justice.

Any other order which the court may deem fit and proper in the
facts and circumstances of the case may be also passed in favor of
the applicant.

APPLICANT

THROUGH
COUNSEL

 
 Application under Section 439 CrPC

IN THE HON'BLE DISTRICT AND SESSION COURT AT BHOPAL

Cr MP (M) No:______ 2021

Applicant/Petitioner

VERSUS

Respondents

Application under Section 439 CrPC for the grant of Bail

Respectfully Sheweth:

1. That the accused Sh. _______ of the applicant has been involved in a false and
frivolous case by one Sh. _______ by lodging a complaint/FIR No. _______ dated
_______ under Sections _______ of IPC with the SHOPS: _______. The accused has
been arrested by the Police of Police Station: ________ subsequent to the above
complaint.

2. That it is submitted that the allegations made against the accused are false, frivolous
and vexatious and lack in the material substance. The accused has nothing to do with
the alleged offences. The accused belongs to a very reputed family in his locality. The
allegations are that _________

3. That the accused is a permanent resident of ________ and earning livelihood by

________. The accused has his old parent’s dependent upon him and the accused is the
only bread earner for the family.

4. That the accused is innocent and has been involved falsely due to the personal grudge
to settle the score against the accused by the _______ due to ________. ________It is
submitted that the complainant is an influential and high-handed person.

5. That by getting the accused arrested the accused has been deprived of his valuable
fundamental right of liberty by abuse of legal provisions and process of law by the
complainant.

6. That the accused is willing to furnish surety and bail bonds to the satisfaction of this
Hon'ble court on being ordered to be released on bail. The accused is also willing to join
the investigations and bind himself by the terms and conditions laid down by the law or
by this Hon'ble court. It is further submitted that the accused is not at all required for
the investigations and the investigations are over. However, if the accused is required
for investigation, the applicant undertakes that the accused will be present as and when
required in accordance with the law.

7. That neither any recovery is to be effected from the accused nor is the accused in a
position to temper with the prosecution evidence. The accused will associate with the
investigation whenever required to do so.

8. That the petitioner submits that no such application on behalf of the accused on the
same or similar grounds has been filed or is pending in any other court.

9. That the accused has immovable property in the said village and is ______self-
employed in the reputed government job and there is no chance of his jumping over the
bail.

10. That the accused further undertakes not to tamper with any prosecution evidence or
terrorize the witnesses.

11. The accused undertakes not to leave the jurisdiction of state of HP and India without
the orders of the Court.

It is, therefore, most respectfully prayed that:-

(a) that the accused may kindly be ordered to be released on bail and this application
for bail may kindly be allowed;
(b) that till the decision of this application interim bail may kindly be granted to the
accused;
(c)________that the directions may kindly be issued to the police to get the accused
medically examined immediately;
(d) Such other orders be also passed in favour of the applicant/accused as deemed fit
and proper in the facts and circumstances of the case and in the interest of justice.

AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN DUTY BOUND, SHALL
EVER PRAY.

Coimbatore Applicant/Petitioner

______

Through, Advocate

Note:-

This application is filed through the father and next friend of the applicant/accused, Sh.
_____. It is, therefore, prayed that the application of the applicant/accused may kindly
be allowed and the applicant/accused may kindly be released on interim bail in the
interest of Justice.

Coimbatore

Applicant

----------------

Through, Advocate

IN THE HON'BLE DISTRICT AND SESSION COURT AT BHOPAL

Cr MP (M) No:______ of 20

Applicant\Petitioner

Versus

State of through Public Prosecutor

Affidavit in support of application under Sec 438 of CrPC

I, ______, do hereby solemnly affirm and declare as under :-

1. That the accompanying application has been prepared under my instructions.

2. That the contents of paras 1 to ________ of the accompanying application are correct
and true to the best of my knowledge.

3. That I further solemnly affirm and declare that this affidavit of mine is true, no part of
it is false and nothing material has been concealed therein.

Affirmed at Bhopal this the ______.

Deponent